Justia Labor & Employment Law Opinion SummariesArticles Posted in Minnesota Supreme Court
Fish v. Ramler Trucking, Inc.
The Supreme Court affirmed the decision of the court of appeals concluding that, by the plain words of Minn. Stat. 604.02, a tortfeasor's liability to an injured employee is not reduced by the employer's fault. At issue was whether the 2003 amendment to Minn. Stat. 604.02, subd. 1 overturned the line of decisions holding that an employer liable to an injured employee under the Workers' Compensation Act and a third party liable in tort to that same employee do not have either joint or several liability. In this case, an employee was injured in the workplace. The employee and his employer settled the workers' compensation claim. The employee brought a negligence against the tortfeasor, which brought a third-party contribution claim against the employer. The jury found that the injury was caused by the employee, the employer, and the tortfeasor. The district court applied section 604.02 to reduce the net damage award to the employee by an amount proportionate to the employer's fault. The court of appeals reversed, concluding that the lower court erred in applying section 604.02 under the circumstances. The Supreme Court affirmed, holding that the tortfeasor's liability to the employee was not reduced by the fault of the employer. View "Fish v. Ramler Trucking, Inc." on Justia Law
Block v. Exterior Remodelers, Inc.
The Supreme Court affirmed the decision of the Workers' Compensation Court of Appeals (WCCA) ruling that Minn. Stat. 176.179 did not apply to Appellant's vacated workers' compensation award, holding that no mistaken compensation was paid, and thus, section 176.179 did not apply. Appellant injured his low back during the course of his employment and entered into a settlement agreement with his employer. The WCCA approved the settlement by an award. Appellant later petitioned to vacate the award, arguing that there was a mutual mistake of fact when the settlement was entered into and a substantial change in his medical condition that could not have been anticipated at the time of the award. The WCCA vacated the award based on the substantial change in Appellant's medical condition. When Appellant then filed a claim petition for additional benefits the parties disagreed as to whether Employer was entitled to a credit for the $40,000 already paid under the vacated award. The compensation judge ruled that section 176.179 did not apply and that Employer was entitled to full credit against Appellant's claim for benefits. The Supreme Court affirmed, holding because no mistake of fact or law occurred, no mistaken compensation was paid and that section 176.179 did not apply. View "Block v. Exterior Remodelers, Inc." on Justia Law
Alby v. BNSF Railway Co.
In this case brought under the Federal Employers' Liability Act (FELA), 45 U.S.C. 51-60, the Supreme Court reversed the decision of the court of appeals affirming the district court's use of the federal post judgment interest rate of .058 percent per year after the district court awarded Employee damages, holding that the state post judgment interest rate applies. In his complaint against his employer, BNSF Railway Company, Employee claimed that he suffered cumulative trauma to his back resulting from his twenty years of employment as a conductor and engineer. The jury decided in favor of Employee. The district court awarded damages and postjudgment interest, applying the federal postjudgment interest rate. The Supreme Court reversed and remanded the case to the district court to apply the ten percent postjudgment interest rate set forth in Minn. Stat. 549.09, subd. 1 (c)(2), holding that postjudgment interest in an action brought under FELA in Minnesota courts is calculated in accordance with Minn. Stat. 549.09, subd. 1(c). View "Alby v. BNSF Railway Co." on Justia Law
Firefighters Union Local 4725 v. City of Brainerd
The Supreme Court affirmed the decision of the court of appeals reversing the judgment of the district court granting summary judgment to the City of Brainerd after the City restructured its fire department and eliminated all of its union positions, holding that the City engaged in an unfair labor practice prohibited by Minn. Stat. 179A.13, subd. 2(2). Firefighters Union Local 4725 and the union president sued the City under the Public Employment Labor Relations Act (PELRA), Minn. Stat. 197A.01-.25, alleging that in eliminating the union positions, the City engaged in unfair labor practices prohibited by PELRA. The district court granted summary judgment for the City. The court of appeals reversed, ruling that the City violated section 179A.13, subd. 2(2) by undergoing a department reorganization that resulted in the dissolution of a bargaining unit. The Supreme Court affirmed, holding that the City's interference with the existence of an employee organization constituted a prohibited unfair labor practice. View "Firefighters Union Local 4725 v. City of Brainerd" on Justia Law
In re Minnesota Living Assistance, Inc.
The Supreme Court reversed the court of appeals' decision reversing the order of the Commissioner of the Department of Labor and Industry for Baywood Home Care to pay unpaid overtime wages and liquidated damages, holding that the court erred in determining that the Commissioner's conclusion that split-day plans are not permitted under the Minnesota Fair Labor Standards Act, Minn. Stat. 177.21-.35, was based on an unpromulgated rule. Baywood paid its employees using a split-day plan even after an employee had worked forty-eight hours in a workweek. The Commissioner issued compliance order ordering Baywood to cease and desist from failing to pay overtime. The court of appeals reversed. The Supreme Court reversed, holding (1) the Act requires employers to pay employees at least time-and-a-half wages for all hours worked in the first forty-eight hours of a given workweek, regardless of whether the employee received time-and-a-half compensation during the first forty-eight hours of employment in that workweek; (2) time-and-a-half payments for regularly scheduled work occurring before an employee has worked forty-eight hours in a workweek may not be excluded from an employee's remuneration to calculate the employee's regular rate; and (3) the Commissioner's failure to promulgate interpretive rules meant that the Department's interpretation did not receive deference, but the Court nevertheless adopted that interpretation. View "In re Minnesota Living Assistance, Inc." on Justia Law
Jackson v. Commissioner of Human Services
The Supreme Court affirmed the judgment of the court of appeals affirming the decision of the Commissioner of the Department of Human Services (DHS) determining that Appellant was permanently disqualified from working in a capacity where he may have contact with people who access services from a DHS-licensed program, holding that Appellant's claims on appeal failed. After DHS discovered a 2002 child-protection report that Appellant had sexually abused his son sometime around 1998, Appellant was disqualified from employment as a residence manager at a DHS-licensed substance abuse treatment program. The court of appeals affirmed DHS's decision. The Supreme Court affirmed, holding (1) Defendant's right to due process was not violated; (2) the Department of Human Services Background Studies Act, Minn. Stat. ch. 245C, does not create a permanent, irrebuttable presumption that DHS's decision was correct; and (3) Appellant was provided constitutionally sufficient notice of his rights under the Act. View "Jackson v. Commissioner of Human Services" on Justia Law
Posted in: Civil Rights, Constitutional Law, Government & Administrative Law, Labor & Employment Law, Minnesota Supreme Court
Noga v. Minnesota Vikings Football Club
The Supreme Court reversed the decision of the Workers' Compensation Court of Appeals (WCCA) affirming a compensation judge's judgment finding that Alapati Noga, a former defensive lineman for the Minnesota Vikings, who now suffers from dementia, was entitled to permanent and total disability benefits, holding that Noga did not satisfy the statute of limitations under Minn. Stat. 176.151. Noga played as a defensive lineman for the Vikings from 1988 until 1992. While playing for the Vikings, Noga experienced head injuries and headaches. In 2015, Noga filed a claim petition for workers' compensation benefits. A compensation judge found that Noga sustained a Gillette injury of "head trauma, brain injury, and/or dementia" that culminated on or about December 1, 1992 and that the injury was a substantial contributing factor to Noga's permanent and total disability.The WCCA vacated certain findings and remanded several issues. On remand, the compensation judge resolved those issues in Noga's favor, determining, among other things, that the statute of limitations was satisfied under Minn. Stat. 176.151 because the Vikings provided Noga with medical care that constituted a "proceeding." The WCCA affirmed. The Supreme Court reversed, holding that the Vikings' provision of care for Noga's head injuries did not constitute a proceeding that prospectively satisfied the statute of limitations. View "Noga v. Minnesota Vikings Football Club" on Justia Law
Posted in: Government & Administrative Law, Labor & Employment Law, Minnesota Supreme Court, Personal Injury
Smith v. Carver County
The Supreme Court reversed the decision of the Workers' Compensation Court of Appeals (WCCA) reversing the judgment of the compensation judge dismissing Petitioner's claim petition seeking workers' compensation benefits for post-traumatic stress disorder (PTSD), which Petitioner claimed resulted from numerous traumatic incidents that he experienced while working, holding that the WCCA erred. At issue on appeal was the correct interpretation of Minn. Stat. 176.011, subs.15(d), which requires an employee seeking workers' compensation benefits where the alleged injury is PTSD arising out of employment to prove that the employee has been diagnosed with PTSD by a licensed psychologist or psychiatrist using the latest version of the Diagnostic and Statistical Manual of Mental Disorders (DSM) in making a diagnosis. The Supreme Court held (1) Minn. Stat. 176.011, subs.15(d) does not require a compensation judge to conduct an independent assessment to verify that the diagnosis of the psychologist or psychiatrist conforms to the PTSD criteria set forth in the DSM before accepting the expert's diagnosis; and (2) the WCCA erred by overriding the compensation judge's choice between two competing medical experts because the expert opinion adopted by the compensation judge had an adequate factual foundation for the diagnosis. View "Smith v. Carver County" on Justia Law
Posted in: Government & Administrative Law, Labor & Employment Law, Minnesota Supreme Court, Personal Injury
Rodriguez v. State Farm Mutual Automobile Insurance Co.
In this case filed by a bus driver who sought reimbursement for chiropractic services related to her work-related injury the Supreme Court affirmed the decision of the court of appeals to reinstate Plaintiff's arbitration award after the district court vacated the award, holding that a provision in the Minnesota Workers' Compensation Act, Minn. Stat. 176.83, subd. 5(c), did not bar coverage. Plaintiff's employer's workers' compensation carrier agreed to pay workers' compensation benefits to Plaintiff but refused to pay for more than twelve weeks of chiropractic care in accordance with the treatment parameters adopted for purposes of the Act. In accordance with that decision, Plaintiff's first chiropractor stopped treatment after twelve weeks of providing care. Plaintiff then received additional care from a different chiropractor. It was for this care that Plaintiff sought reimbursement from State Farm, her personal automobile no-fault insurer. State Farm denied coverage. An arbitrator ruled in favor of Plaintiff and awarded her the full amount she sought. The district court vacated the arbitrator's award, and the court of appeals reversed. The Supreme Court affirmed, holding that the statutory prohibition on reimbursement in section 176.83, subd. 5(c) is limited to the first provider whose services the workers' compensation payer determined to be excessive. View "Rodriguez v. State Farm Mutual Automobile Insurance Co." on Justia Law
Posted in: Arbitration & Mediation, Labor & Employment Law, Minnesota Supreme Court, Personal Injury
Svihel Vegetable Farm, Inc. v. Department of Employment & Economic Development
The Supreme Court affirmed the decision of the court of appeals affirming the decision of an unemployment law judge upholding the determination of the Minnesota Department of Employment and Economic Development that the wages Appellant paid to workers who hold H-2A and J-1 visas are subject to unemployment insurance taxation, holding that the court of appeals did not err in concluding that Appellant owed the taxes. Appellant, a corporation that grows and sells fruits and vegetables, began hiring H-2A and J-1 nonimmigrant visa holders in 2010. In 2016, the Department of Employment and Economic Development determined that Appellant owed $154,726 in unpaid unemployment insurance taxes, mostly on the wages of the H-2A and J-1 visa workers. An unemployment judge upheld the determination, concluding that the visa workers' wages were subject to unemployment insurance taxation under Minnesota law. The court of appeals affirmed. The Supreme Court affirmed, holding that Appellant must pay unemployment insurance taxes on these workers' wages. View "Svihel Vegetable Farm, Inc. v. Department of Employment & Economic Development" on Justia Law